Opinion
1:22-cv-01189
03-15-2022
JAMES L. RADERS, Plaintiff, v. MICHAEL D. FRANTZ, FRANTZ COMMUNITY INVESTORS, L.L.C, and FRANTZ VENTURES, L.L.C., Defendants.
Thomas J. McDonell (ARDC No. 6317275) QUARLES & BRADY LLP
Thomas J. McDonell (ARDC No. 6317275) QUARLES & BRADY LLP
PLAINTIFF'S MOTION FOR ENTRY OF MEMORANDUM OF JUDGMENT
Franklin U. Valderrama, Judge
James L. Raders (“Plaintiff”), through its attorneys, Quarles & Brady LLP, respectfully requests that this Court enter a Memorandum of Judgment on behalf of Plaintiff. In support hereof, Plaintiff states as follows.
1. On February 2, 2022, a judgment was entered in the United States District Court, Middle District of Florida, Orlando Division, in favor of Plaintiff and against Michael D. Frantz, Frantz Community Investors, .L.C, and Frantz Ventures, L.L.C. (“Defendants”) in the amount of $4,200,000.00 (the “Florida Judgment”).
2. On March 7, 2022, the Florida Judgment was registered in this Court and was assigned to the Honorable Franklin Valderrama. The certified copy of the Florida Judgment that was registered in this Court on March 7, 2022 is attached hereto as Exhibit A.
3. Defendants have not filed an appeal of the Florida Judgment.
WHEREFORE, for the reasons stated herein, Plaintiff respectfully requests that this Court enter the Memorandum of Judgment attached hereto as Exhibit B.
EXHIBIT A
AFFIDAVIT IN SUPPORT OF NOTICE OF FILING TO REGISTER FOREIGN JUDGMENT
Thomas J. McDonell, attorney for Judgment Creditor, James R. Raders, certifies and states as follows.
1. The last known address of Plaintiff/Judgment Creditor, James R. Raders, is 915 Bryce Lane West, Melbourne, FL 32904.
2. The last known addresses of the Defendant/Judgment Debtor, Michael D. Frantz, is 1443 Woodhill Drive, Northbrook, IL 60062 and 715 Arrowhead Drive, Fontana, WI 53125.
3. The last known address of the Defendant/Judgment Debtor, Frantz Community Investors, L.L.C., is 3801 Beverly Road, Suite 300, Cedar Rapids, IA 52404.
4. The last known address of the Defendant/Judgment Debtor, Frantz Ventures, L.L.C., is 1443 Woodhill Drive, Northbrook, IL 60062.
Under penalties of perjury as provided by law I certify that the statements set forth in this Affidavit are true and correct, except as to matters therein stated to be on information and belief, and as to such matters I verily believe the same to be true.
EXHIBIT B
MEMORANDUM OF JUDGMENT
On March 7, 2022, a foreign Judgment in a Civil Case was entered in favor of Plaintiff, James L. Raders, and against Michael D. Frantz, Frantz Community Investors, L.L.C., and Frantz Ventures, L.L.C. ("Defendants") in the amount of $4,200,000.00. The last known addresses of Defendants are:
Michael D. Frantz, 1443 Woodhill Drive, Northbrook, IL 60062;
Michael D. Frantz, 715 Arrowhead Drive, Fontana, WI 53125;
Frantz Community Investors, L.L.C., 3801 Beverly Road, Suite 300, Cedar Rapids, IA 52404; and
Frantz Ventures, L.L.C., 1443 Woodhill Drive, Northbrook, IL 60062.